Our comments regarding the…

Our comments regarding the proposed new agricultural system mapping and implementation procedures are summarized below:

• The areas identified on the draft agricultural land base mapping as “Areas currently designated Agricultural (municipal official plans, 2015)” do not appear to align with the areas designated as “Agricultural” on Schedule 5.1 of the County of Simcoe Official Plan.

• The County Official Plan Agricultural designation and mapping has been used as a basis for the draft Agricultural land use designation and mapping in the Township’s new draft Official Plan, so there are some significant differences between the draft agricultural land base mapping and the draft Official Plan mapping.

• The most significant difference appears to be that the draft agricultural land base map includes areas that are designated as “Greenlands” in the County Official Plan as part of the proposed prime agricultural areas.

• To illustrate the extent of these mapping differences, the Agricultural System Map Overlay attached to this letter overlays the Township draft Official Plan land use designations with the draft agricultural land base mapping.

• There are many large treed areas/woodlots and also some watercourses/natural corridors that are proposed to be designated as prime agricultural areas on the draft agricultural land base map. It is unclear why such natural areas would be deemed to be part of the prime agricultural areas if such areas are to be conserved in a natural state as per the current County Greenlands designation and the draft Natural Heritage System mapping.

• The areas identified by OMAFRA to be added to the prime agricultural areas include lands east of Gratrix Road and west of Old Coach Road, as well as lands south of Hogg Valley Road between Newton Street and Gervais Road.

• The lands east of Gratrix Road are entirely treed and are currently designated as Greenlands in the County Official Plan, and are proposed to be designated as Greenlands in the draft Township Official Plan. It is unclear why such natural areas are proposed to be designated as prime agricultural areas.

• Similarly, much of the lands south of Hogg Valley Road between Newton Street and Gervais Road are natural lands and it is unclear why most of these lands are identified as prime agricultural areas on the draft agricultural land base map.

• There are three areas in the Township that are identified on the draft agricultural land base map as “Candidate areas for the Agricultural Land Base (AAFC and OMAFRA)”. While some portions of these areas are proposed to be designated as Agricultural in the Township’s draft Official Plan, much of these areas are existing wooded areas and natural environment lands that are within the current Greenlands designation in the County Official Plan and draft Township Official Plan. Similar to other lands identified herein, it is unclear why large woodlands and other natural areas would be included in the draft agricultural land base mapping if these areas are protected as Greenlands and part of the Natural Heritage System.

• The draft mapping and implementation procedures create confusion on the purpose and effect of the mapping, the timeline and process for the mapping to become effective, and how to interpret and apply current planning policies at all levels particularly given the extent of the differences among the Provincial and County/Township mapping.

The draft Implementation Procures create uncertainty and ambiguity regarding the implementation of the draft mapping and should be clarified to address the questions raised at the September 25th meeting (copy of questions attached).

• To allow sufficient time to review the mapping in detail and properly refine and implement the agricultural land base mapping, the procedures should provide that the mapping becomes effective through updates to upper- and lower-tier official plans.

Questions for Province and County

September 25, 2017

GHH Agricultural System – Implementation Procedures

1. Where land is identified by OMAFRA as “Prime Agricultural Areas” on the agricultural land base map, does the land automatically fall under the prime agricultural area definitions and policies of the PPS and Growth Plan? What if the land is not designated as prime agricultural area or equivalent designation in the upper-tier and local Official Plans and the Official Plans have not yet been updated to reflect and refine the mapping of the prime agricultural areas on the agricultural land base maps?

2. Can local municipal Official Plans be approved based on locally generated mapping of prime agricultural areas before the upper tier Official Plan has been updated to implement and refine the new Provincial Agricultural Land Base mapping?

3. We currently in the draft Official Plan we have multiple references to protecting agricultural lands specifically (3.6.1) Resource Management Policies (Prime Agricultural Areas)

Given the Province’s recent statements that the Provincial Ag mapping can be refined on a County and lower tier basis, can reference be made to this in the policy e.g. “… mapping as refined by the County and/or the Township”

4. Subsection 2.1.2 references the LEAR and other analysis undertaken by OMAFRA. Where can this information be accessed to see the LEAR scores and other analysis performed for specific geographic areas?

5. Section 3.1.1.1 refers to recent studies that may demonstrate that existing designated areas are not prime agricultural areas. Does “existing designated areas” refer to prime agricultural areas already designated in municipal official plans, or prime agricultural areas identified by OMAFRA on the agricultural land base map, or both? What is the required scope and content of these studies? Is this referring to LEAR studies?

6. Are sections 2.1.2.3 and 3.1.1.2 to be interpreted to mean that there are areas that may be designated as “rural lands” within the darker brown shaded prime agricultural areas on the agricultural land base map, at the time of municipal refinement? Or, are these sections only applicable to the lighter brown shaded candidate areas identified as having agricultural potential on the agricultural land base map? The section title of 2.1.2.3 would indicate that the section only applies to the candidate areas (lighter shade of brown on the map).

7. For an area that is currently designated as rural lands within the official plan and is identified as prime agricultural area on the agricultural land base map, does the current rural lands designation continue to apply until

new official plan mapping has been created through the municipal refinement process?

8. Where lands in the prime agricultural area or candidate areas contain existing non-agricultural uses, are municipalities permitted to recognize these existing non-agricultural uses with appropriate land use designations and zoning? How is it determined if an area of existing land use is large enough to warrant a site-specific designation? Are existing uses permitted to expand?

9. Is it required that the unshaded white lands on the agricultural land base map shall be designated as rural lands, or may they be designated for other purposes? Where lands in the white areas on the map (outside of the agricultural land base) contain existing uses, are municipalities permitted to recognize these existing uses with appropriate land use designations and zoning? How is it determined if an area of existing land use is large enough to warrant a site-specific designation? Are existing uses permitted to expand?

10. Is section 3.1.4 to be interpreted to mean that the agricultural land base map has no bearing on the determination of permitted uses and applicable policies for specific properties until ALL of the GGH municipal refinement processes are completed with ALL official plans updated and a final provincial agricultural land base map has been issued to reflect these refinements?

11. Until the municipal refinement process is complete and all official plans are updated and a final agricultural land base map is issued by the Province, do existing land use designations and policies in existing official plans continue to apply?

[Original Comment ID: 211041]